CMA vets order: £21 prescription cap and published price lists

What the Order does

Source: Competition and Markets Authority, GOV.UK, 22 September 2026. Image: CMA, Crown copyright, OGL v3.0.

The Veterinary Services Market Investigation Order 2026 was published on 22 September 2026, alongside undertakings accepted from the Royal College of Veterinary Surgeons. The Order makes the remedies set out in the CMA's March 2026 final report legally binding on veterinary businesses operating first opinion practices. It does not apply to charities providing small animal veterinary services. The CMA has been examining the veterinary services market since September 2023, and the Order is the point at which the remedies move from recommendations into enforceable obligations.

If a business does not comply, the CMA can work with it to change practices, issue binding directions, or impose a financial penalty. The Order sets different compliance clocks depending on the size of the business. Larger businesses are those with 15 or more first opinion practices. Smaller businesses generally have more time to comply. That distinction runs through the prescription fee cap, the prescription offer, price list publication, estimates and bills, and cremation information. The Order also covers ownership transparency, out-of-hours contracts and data sharing with the RCVS. The practical effect is that the CMA's timetable now governs what practices must publish, offer and provide, and by when.

Prescription fees capped at 21 pounds

The prescription fee cap is a maximum of 21 pounds for the first medicine prescribed within a consultation and 12.50 pounds for each additional medicine in the same consultation. The cap is inclusive of VAT, applies UK-wide, and is adjusted annually for CPI. Larger businesses have 6 months from the Order to comply, and smaller ones have 12 months. The cap sits alongside a separate requirement on written prescriptions. Vets must orally offer a written prescription in every consultation where medicine is prescribed, except where urgent administration is needed. The prescription must then be provided in hard copy by the end of the consultation or digitally within 48 hours. Larger businesses have 9 months for that requirement, and smaller ones have 12.

There is also a rule on own-brand medicines. When prescribing an own-brand medicine, vets must tell the pet owner that the reference product alternative is available from third parties such as online pharmacies, and must name it on labels and invoices. Taken together, these measures change what a pet owner is told at the point of prescribing and what appears on the paperwork afterwards. The 21 pounds cap applies to the fee for the first medicine prescribed in a consultation, not to the cost of the medicine itself. The annual CPI adjustment means the figures are not fixed permanently. The compliance dates differ by business size, so the cap and the prescription offer will not arrive at the same time across every practice.

Price lists online and in the waiting room

Businesses must publish standard price lists online, one click from the homepage, and in practice. The lists cover a defined set of services including first and repeat consultations, out-of-hours consultation, vaccinations, microchipping, prescription and dispensing fees, dental, castration, spay, X-ray, ultrasound, CT and MRI, pre-anaesthetic blood tests, euthanasia, and communal and individual cremation. Prices must include VAT and be given for pet weight bands, from cats and small dogs under 10kg to giant dogs over 60kg. Price lists, parasiticide price lists and pet care plan information are due from larger businesses within 3 months, which is December 2026, and from smaller businesses within 6 months, which is March 2027.

The parasiticide price lists cover the most commonly sold flea, tick and worm products and must include a link to the VMD Register of Online Retailers. Pet care plan information must set out contents and standalone prices. Groups must also clearly display ownership of practices online, in signage and in communications within 6 months. Separately, businesses must supply practice, price and plan data to the RCVS within 12 months for an enhanced Find a Vet service, and the RCVS may share that data with approved comparison sites. For pet owners, the effect is that a defined set of common services and products should be priced in public, in a consistent format, with VAT included and weight bands applied, rather than being available only on request at the counter.

Estimates, itemised bills and complaints

Written estimates are required when a recommended treatment pathway is reasonably likely to cost 500 pounds or more including VAT. A written update is required if the cost is likely to rise by 20% or 500 pounds, whichever is lower. Itemised bills are also required. Larger businesses have 9 months for these requirements and smaller ones have 12. The 500 pounds threshold will be CPI-adjusted. These obligations apply to the recommended pathway, so the trigger is the expected cost of the treatment being discussed, not the final invoice after the event. The written update requirement means that a material change in expected cost should be documented rather than only mentioned in conversation.

On complaints, businesses must have a written in-house process published on the website, acknowledge a complaint within 5 working days once it is actionable, provide a full response within 8 weeks, keep a complaint log, and participate in mediation via an approved ADR provider. These requirements apply within 6 months for all businesses. All practices must offer a basic communal cremation and publish prices for communal and individual cremation and for optional add-ons. Larger businesses have 3 months for that and smaller ones have 6. Out-of-hours contracts between practices and third-party providers may not have notice periods longer than 12 months, effective immediately. The combination of estimates, itemised bills, a published complaints route and cremation pricing gives pet owners a documented paper trail at the points where costs and decisions are most likely to be disputed.

What it means for pet insurance claims

Written estimates and itemised bills give policyholders and insurers a clearer basis for claims, excess decisions and disputes. An estimate produced before a recommended treatment pathway begins, and updated in writing if the expected cost rises by 20% or 500 pounds, creates a dated record of what was expected and when. An itemised bill separates the components of a claim rather than presenting a single total. For a pet owner weighing an excess, a co-payment or an annual limit, that separation can make the difference between a claim that is straightforward to submit and one that needs chasing for breakdowns. The price list requirements add a public reference point for common services, including consultations, vaccinations, neutering, dental, X-ray and euthanasia, with VAT included and prices given by pet weight band.

The prescription changes also touch on claim paperwork. A written prescription offered orally in every consultation where medicine is prescribed, and provided in hard copy by the end of the consultation or digitally within 48 hours, gives a document that names the medicine. Where an own-brand medicine is prescribed, the reference product alternative must be named on labels and invoices. For insurance purposes, that naming can matter when a claim relates to a specific medicine rather than a category of treatment. The Order does not change policy terms, excess levels or what an insurer will pay. It changes what practices must publish and provide. The practical link is documentation: estimates, itemised bills, named medicines and published prices all feed into the evidence a policyholder assembles when making a claim. KT pet insurance guides cover the policy side of claims and excess decisions.

Source: CMA: Veterinary Services Market Investigation Order 2026 and RCVS Undertakings.

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Frequently asked questions

When did the CMA vets Order take effect?

The Veterinary Services Market Investigation Order 2026 was published on 22 September 2026, alongside Royal College of Veterinary Surgeons undertakings accepted in line with the CMA timetable of Order made September 2026. It makes the remedies in the CMA's March 2026 final report legally binding on veterinary businesses operating first opinion practices.

What is the prescription fee cap?

A maximum of 21 pounds for the first medicine prescribed within a consultation and 12.50 pounds for each additional medicine in the same consultation, inclusive of VAT, UK-wide, and adjusted annually for CPI. Larger businesses have 6 months from the Order and smaller ones have 12 months.

When must price lists be published?

Price lists, parasiticide price lists and pet care plan information are due from larger businesses within 3 months, which is December 2026, and from smaller businesses within 6 months, which is March 2027. Lists must appear online one click from the homepage and in practice, with VAT-inclusive prices by pet weight band.

When is a written estimate required?

When a recommended treatment pathway is reasonably likely to cost 500 pounds or more including VAT, with a written update if the cost is likely to rise by 20% or 500 pounds, whichever is lower. Itemised bills are also required. Larger businesses have 9 months and smaller ones have 12.

Which businesses have longer to comply?

Larger businesses are those with 15 or more first opinion practices. Smaller businesses generally have more time to comply across the prescription fee cap, the prescription offer, price list publication, estimates and bills, and cremation information.